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SO2 labelling

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Abc Project

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Posted 15 February 2022 - 12:41 PM

Hi Everyone,

I have a situation that the SO2 content in starch is above 10 mg / kg. When I use this starch to make a pudding powder mix, the amount of SO2 in the pudding powder mix is above 10 mg / kg.
When the consumer prepares the pudding according to the instructions (mixing the powder mixture with milk), the SO2 content in the finished ready-to-eat product is less than 10 mg / kg.
In this case, is it necessary to declare the presence of CO2 as an allergen according to EU regulations?
Thank you for your response

 

Резултати преводаI have a situation that the SO2 content in starch is above 10 mg / kg. When I use this starch to make a pudding powder mix, the amount of SO2 in the pudding powder mix is above 10 mg / kg. When the consumer prepares the pudding according to the instructions (mixing the powder mixture with milk), the SO2 content in the finished ready-to-eat product is less than 10 mg / kg. In this case, is it necessary to declare the presence of CO2 as an allergen according to EU regulations?

 



pHruit

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Posted 15 February 2022 - 02:14 PM

Strictly speaking, this is not a declarable allergen under regulation (EU) 1169/2011 - see appendix II:

Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre in terms of the total SO2 which are to be calculated for products as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers

 

Since your instructions for the product "as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers" does not contain SO2 above the 10mg threshold, this wouldn't be considered an allergen.

Nonetheless you might want to check local regulations/interpretation/preferences around any additional warning statements.
I can't imagine anyone eating powdered pudding mix without reconstituting it, so the chance of actually consuming sulphites at a level >10mg/kg would seem to be low, and indeed it's not a "true" allergen in the same sense as those for which very small traces of proteins could trigger a reaction.



Brendan Triplett

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Posted 15 February 2022 - 02:18 PM

You mention CO2 and SO2 in this question.  For arguments' sake I am going to assume you are talking about SO2 since it is the allergen.

 

That depends on if the product can be considered ready-to-eat, as is.  If it is then yes it needs to be labeled.  If no, and the product needs to be reconstituted, then you would be looking at the final form of the product and you would not need to label it.  Here is the EU guidance:

 

Sulphur dioxide and/ or sulphites at concentrations of more than 10 mg/kg or 10 mg/ (litre) in terms of the total SO2 which are to be calculated for products as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers.

 

Full guidance is here:

 

Guidance template (food.gov.uk)

 

Bullet 51. 

51. References to sulphur dioxide and/ or sulphites, which are used and found present in the finished product (ready for consumption or reconstituted according to manufacturers’ instructions) at less than 10 mg/Kg or 10 mg/litre is not required.

 

Hope this helps. 

 

Cheers!


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Brendan Triplett

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Posted 15 February 2022 - 02:20 PM

Strictly speaking, this is not a declarable allergen under regulation (EU) 1169/2011 - see appendix II:

Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre in terms of the total SO2 which are to be calculated for products as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers

 

Since your instructions for the product "as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers" does not contain SO2 above the 10mg threshold, this wouldn't be considered an allergen.

Nonetheless you might want to check local regulations/interpretation/preferences around any additional warning statements.
I can't imagine anyone eating powdered pudding mix without reconstituting it, so the chance of actually consuming sulphites at a level >10mg/kg would seem to be low, and indeed it's not a "true" allergen in the same sense as those for which very small traces of proteins could trigger a reaction.

 

Beat me out on the response while I was typing lol


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